1. Financial Services Workshop Presentation
EAST CAROLINA UNIVERSITY
OFFICE OF GRANTS AND CONTRACTS (OGC)
Financial Services Workshop
Presentation
For additional information
or contact your OGC representative
February 15,2007

2. What will be covered: Subawards Scholarships Closeout
EAST CAROLINA UNIVERSITY
OFFICE OF GRANTS AND CONTRACTS (OGC)
What will be covered:
Subawards
Scholarships
Closeout

3. SUBRECIPIENTS POST-AWARD PROCEDURES
EAST CAROLINA UNIVERSITY
OFFICE OF GRANTS AND CONTRACTS (OGC)
SUBRECIPIENTS
POST-AWARD PROCEDURES

4. INTRODUCTION
The Uniform Guidance (2 CFR 200) enhances the requirements for subrecipient monitoring in four major areas:
Proposal Stage
Award Stage
On-Going Monitoring and
Closeout Stage
After the proposal review, and the initial risk assessment, and the Office of Sponsored Programs (OSP) has issued the subagreement, the following slides outline Principal Investigator (PI), Departmental and Institutional requirements for
Closeout

5. OGC – RISK ASSESSMENT
UG requires an evaluation of each subrecipient’ s risk of non-compliance with federal requirements.
The initial risk assessment/form will be started by OSP as part of the subaward initiation process.
As part of the initiation process, OSP will secure a subrecipient commitment form which includes representations and certifications outlining the sub’s status, business practices, and compliance with programmatic and financial reporting and audit requirements.
OGC completes the risk assessment and reviews the commitment certification to determines if the sub is low, medium, or high risk. Based on the sub’s status:
Additional language/requirements may be added to the agreement terms/conditions.
The agreement may be financially desk-audited one or multiple times.
All cost-reimbursement subs will be financially desk-audited at least once in each budget year. 5

6. OGC – RISK ASSESSMENT
High risk subs may be required to include backup documents for all invoices or may need additional reporting requirements.
High risk subs may need more detailed business systems reviews and/or site audits.
Fixed price subs will be reviewed on the basis of reporting requirements and other deliverables.
UG allows for fixed price subs under federal awards only if:
The total anticipated cost (entire project period) is less than $150,000 and
The award-specific sponsor has approved a fixed price agreement. 6

7. MONITORING
The Uniform Guidance requires on-going financial monitoring and programmatic assessment for each subaward, for the life of the agreement.
PIs, Departmental Administrators and OGC/OSP have shared responsibility to help ensure the subrecipient’s compliance with all requirements of the subaward, the prime sponsor award, and the Uniform Guidance and other federal regulations. 7

8. ON-GOING MONITORING - OGC
Throughout the Life of the Award
Will conduct desk audits of subrecipient invoices.
Will complete an annual review of the sub’s A-133 audit status or other audit reports and
Will monitor any audit findings or compliance issues.
May include issuing management decisions or corrective action plans or requiring additional invoicing requirements.
Will review sub’s invoices for compliance with award terms and conditions and allowable expenditure requirements.
Will approve all subrecipient invoices prior to processing by AP.
Most payment requests will be via PORT.

9. ON-GOING MONITORING - OGC
Throughout the Life of the Award
Will periodically monitor sub’s technical progress and compliance with other reporting requirements.
PIs may be contacted periodically to verify adequate performance.
PIs will certify adequate performance with invoice approvals.
Will work with the PI/Departmental Administrator regarding any concerns on technical progress, expenditures or other sub issues.
Will work with OSP regarding any necessary modifications to the agreement terms.

10. ON-GOING MONITORING - PI
Throughout the Life of the Award
The Principal Investigator is responsible for ensuring satisfactory technical/scientific progress and compliance with all programmatic goals and technical reporting requirements.
The PI should monitor the subrecipient for timely submission of necessary data, reports, publications and other deliverables.
The PI should verify all deliverables are being met before certifying an invoice or processing a payment.
The PI must review and approve all sub invoices and include a certification statement and signature on/with each invoice for payment.
“By my signature, I verify that the subcontractor is adequately performing under the terms of the agreement (data, reporting, etc.). I understand that I should contact/advise OGC if there are any performance or other issues related to this subagreement. The invoice should be paid. __________________(signature)”
Invoices normally should be reviewed/processed within 30-days of receipt.

11. ON-GOING MONITORING - PI
Throughout the Life of the Award
Invoices should not be paid if there are any programmatic, reporting or deliverables problems.
PI should contact OGC immediately if there are any concerns related to sub performance requirements, invoicing, expenditures, or continuation of the relationship.
PI should not just “hold” invoices. Contact OGC immediately to discuss.
A specific OGC institutional notification process is required if there are problems and payment will be “held”.
Informal notification of concerns between the PI and collaborators is not legally binding.
OGC/OSP must give formal notice of any issues or concerns or
Any anticipated changes in the agreement terms, conditions, period of performance, budget or payment schedule.

12. ON-GOING MONITORING - ADMINISTRATOR
THROUGHOUT THE LIFE OF THE AWARD
The Departmental Administrator (DA) serves as the liaison between the PI and OGC/OSP and the ECU business systems.
The DA should contact OGC if there are any issues related to the sub’s performance, reporting, expenditures or payment processing.
The DA should (in conjunction with the PI):
Review the invoice for mathematical accuracy, conformance with subagreement requirements, and total cumulative expenditures.
Monitor for missing invoices or missing payments.
Report any errors/problems in invoicing to OGC for resolution with the sub entity.
Ensure approval, signature, certification of the PI for all invoices.
Accurately process the invoice through the PORT (or other payment system) ensuring that the correct payee, amount and FOAP are used.
Verify that all deliverables have been met before processing the final invoice for payment.

13. ON-GOING MONITORING – PI AND ADMINISTRATOR
Throughout the Life of the Award
All invoices should be reviewed for reasonableness and allowability based on the original budget, program goals and prime sponsor requirements.
Invoice tracking and subagreement projections should be maintained on a cumulative basis.
Contact OGC for any questions related to invoicing - prior to contacting the sub entity.
Clarification/justification might need to be requested for:
Unusual expenditures or expenditures in categories not originally proposed. For example:
Equipment expenses when equipment was not originally anticipated,
Foreign travel when travel or field work was not originally anticipated.
Burn/expenditure rates exceeding the performance reporting/deliverables.
Any significant changes in line-item budgets.
Revised budgets exceeding prior approval authority.
Any costs requiring ECU or sponsor prior approval.
Large expenditures in the last 90-days.

14. ACTIONS THAT CAN BE TAKEN
All official correspondence must be through OGC or OSP. PIs and Departmental Administrators should not take any of these actions without institutional approval.
Based on performance or financial issues related to the subagreement, ECU might -
Increase frequency of audit/desk review.
Require increased documentation with invoices.
Increase prior approval requirements.
Issue a management letter, requiring a corrective action plan by the sub-entity, in order to continue the agreement.
Hold payments pending resolution of issues.
Disallow costs or require payback of costs.
Early terminate the specific agreement.
For fixed rate awards, require cost-reimbursement processing for any future agreements/payments or vice versa.
Suspend/Debar the sub entity from future agreements with ECU.
Notify sponsoring agency of issues.

15. CLOSEOUT
Final payment will not be made until PI/DA has verified that all deliverables have been met.
Final payment will not be made until all outstanding desk audit documents are received/approved by OGC.
Final payment will not be made until final resolution of any disallowed costs, management plans or audits.
For the fiscal year in which the subagreement ends, OGC will monitor the annual A-133 audit, after the agreement end date, to ensure there were no findings that may have impacted sub activity that may still need to be addressed.
Based on audit filings, subs may need to reopened and reaudited.

16. EAST CAROLINA UNIVERSITY OFFICE OF GRANTS AND CONTRACTS (OGC)
Scholarships

17. EAST CAROLINA UNIVERSITY OFFICE OF GRANTS AND CONTRACTS (OGC)
Issuing a Scholarship
Complete a scholarship form, paying special attention to the following:
Academic Year
Detail Code (received from your Financial Analyst)
Include Information in Special Instruction Box
Note: Minimum Disbursable Hours Column must be filled out if the student is less than full time.
Complete the Scholarship Committee Survey Form
Submit the completed forms to

18. EAST CAROLINA UNIVERSITY OFFICE OF GRANTS AND CONTRACTS (OGC)

19. EAST CAROLINA UNIVERSITY OFFICE OF GRANTS AND CONTRACTS (OGC)

20. EAST CAROLINA UNIVERSITY OFFICE OF GRANTS AND CONTRACTS (OGC)
Pulling All of A Scholarship Back
Submit a new scholarship form with a negative number.
Example: If a department originally submitted a scholarship form for $2500 they would submit a new form with ($2500) under the same semester originally submitted in.

21. EAST CAROLINA UNIVERSITY OFFICE OF GRANTS AND CONTRACTS (OGC)
Reducing the Scholarship Amount
Submit a revised form showing only the revised amount the student should receive.
Example: If a department submitted a form with $2500 and the student should only receive $2000, then the department should submit a new form with $2000 under the same semester it was originally submitted in. DO NOT SHOW ($500)

22. EAST CAROLINA UNIVERSITY OFFICE OF GRANTS AND CONTRACTS (OGC)
AWARD CLOSEOUT

23. TYPES OF CLOSEOUT Financial/Administrative Financial Report or Invoice
Cost Share
Inventory
Request for Title or Disposition Instructions
Assignment of Refunds and Rebates
Agency Release
Scientific/Technical
Progress/Technical Report
Invention
Data Sets or Other Deliverables
Theses or Dissertations
Publications

24. TYPES OF CLOSEOUT University Systems All Payments Received
All Expenses Booked
All Encumbrances Cleared
All Deficits/Residuals Cleared
Fund Reconciled to FFR/Invoice
Fund Inactivated in the Accounting System
Data Archives
Financial/Admin
Scientific/Technical

25. CONSEQUENCES
Failure to Submit Final Reports on a Timely Basis Can Lead To:
Disallowed Costs
Award Reduction or Withholding Payment
Delay in Renewal/Continuation Awards
Suspended From Future Awards
Increased Audit Scrutiny
Audit Findings
Suspended From Letter of Credit
Negative Reputation with Sponsor/Program Officer
Failure to Closeout Accounts (Timely) in Accounting System Can Lead To:
Unnecessary Increase in Work Burden
Unnecessary Increase in Administrative Costs
Unnecessary Cash Management Resources Used

26. FIRST STEPS Closeout Begins with the Receipt of the Award
Read the Terms and Conditions
Read the Statement of Work/Requirements
Catalog Allowability, Rebudgeting and Other Requirements or Restrictions
Identify Types of Reports Required
Identify Who is Responsible for the Reports
Identify Due Dates for the Reports
Establish Allowability/Budget Projection/Cost Share Plan

27. MIDDLE STRATEGIES
Good Project Management Leads to Clean, Timely Closeout
Monitor Expenditures/Budgets/Progress on a Regular (Monthly) Basis
Maintain Good Projections and Reconciliation Processes for Plan to Actual and Adjust Plan as Needed
If Report Format Will Be Different Than University System – Maintain Shadow Report and Regroup on a Regular Basis – Don’t Wait Until the End

28. LIFE OF THE AWARD
Monitor Subagreement Progress and Expenditures – Adjust Projections and Modify Sub as Needed
Monitor Allowability on a Regular (Monthly) Basis.
Remove Inappropriate Costs on a Timely Basis (<90 Days)
Reallocate Missing Charges to the Award on a Timely Basis (<90 Days)
Terminate Recurring Expenditures on a Timely Basis (E.G. Payroll Charges)
Track Cost Share and Effort on a Regular (Quarterly) Basis

29. LIFE OF THE AWARD Multi-Year Awards
Treat Annual Budget Period Like a Termination and Complete Full Review on an Annual Basis
Allowability
Cost Share
Effort
Rebudgeting
Carryover
Deficit
Subcontractor Activities
Technical Progress

30. SEMI-FINAL TASKS 6 Months Before Term Comprehensive Budget Projection
Comprehensive Cost Share Review
Comprehensive Effort Review
Comprehensive Allowability Review
Adjust Planned Expenditures as Needed
Reallocations if Needed
Final Equipment or Large Supply Items Should be Processed “Now”
Avoid Equipment, Large Supply Orders and Significant Reallocations in the Last 90 Days
Check for Subcontractor Residuals to Repurpose
Assess Need for No-Cost Extension – Request Early
Rebudgeting – Request “Now” if Sponsor Approval is Needed

31. FINAL STRATEGIES 90 Days Before Term
Contact All Stake Holders RE: Termination
All the Previous Reviews…
Once More – For Real This Time!
Terminate HR/Payroll Forms
Terminate Standing Orders
Liquidate or Clear Encumbrances
Review Report Requirements/Forms/Deadlines
Reminder to Sub RE: Due Dates for Invoices and Deliverables
Book All Outstanding Costs
Travel
Employee Reimbursements
Receiving
Salary Reallocations
Other Reallocations
Cost Share

32. FINAL TASKS – BEST PRACTICES (Actual Dates May Vary By Sponsor/Agreement)
30 Days From Term (Earlier is Better)
All Expenditures Booked (Including Cost Share)
All Encumbrances Cleared
All Deficits Cleared
All Unallowables Cleared
Final Subcontract Invoice Paid
60 Days From Term (Earlier is Better)
Final F&A Review/Adjustment
Final Allowability Review
Final Cost Share Review
All Residuals Cleared
90 Days From Term (Earlier is Better)
All Final Reports Submitter
Final Payment Received
120 Days From Term (Earlier is Better)
Account Closed in the Accounting System

33. Questions?
For questions please contact your OGC representative at or us at